Spatial Land Analysis 

Pred.Jion Agric:ultural Analyld.s 

The Honorable Michael P. Huerta 

Office of the Administrator 

Federal Aviation Administration 

800 Independence Avenue SW 

Washington, DC 20591 

August 31, 2015 

Sean Wagner 

Spatial Land Analysis CEO 

Spatial Land Analysis 

11824 Manning Park Ct 

Bakersfield, CA 93311 

Tel {559) 544-1813 

RE: Spatial Land Analysis sUAS Petition for Exemption Pursuant to FMRA Sec 333 

and 14 CFR Part 11 

Dear Administrator Huerta: 

Spatial Land Analysis, LLC ('Spatial Land Analysis') hereby petitions the FAA for regulatory relief 

pursuant to Section 333 of P.L. 112- 95 and14 C.F.R. Sec. 11.81 to conduct commercial flights using 

the Agribotix Enduro Quad and 3DR Solo Agco Edition sUAS for the following applications: 

• Precision Agriculture Smvey 

• Thermal Agriculture Survey 

Spatial Land Analysis, therefore, seeks a request for exemption from airworthiness and the following 

specific Title 14 C.F.R. provisions: 

• 14 C.F.R. Part 21 

• 14 C.F.R. 45.23 

• 14 C.F.R. 61.113(a) (b) 

• 14 C.F.R. 61.133(a) 

• 14 C.F.R. 91.7(a) 

• 14 C.F.R. 91.9 

• 14 C.F.R. 91.109(a) 

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• 14 C.F.R. 91.119 

• 14 C.F.R. 91.121 

• 14 C.F.R. 91.151(a) 

• 14 C.F.R. 91.203 

• 14 CFR 91.405 (a); 407 (a) (1); 409 (a) (2); 417(a) (b) 

The FAA has issued grants of exemption in circumstances similar in all material respects to those 

presented in this petition, specifically Exemptions No. 12098 to Agribotix, LLC, 12114 to Agrilmage, LLC, and 12091 to Farm Crisp Holdings Inc; and we therefore request that our petition be 

granted without delay. Additional similar exemptions include (precision agriculture) No. 11830, 

11193,11170,11194, 11192, 11177, and 11166. 

Spatial Land Analysis has also provided supporting documentation to include; a General Operations 

Manual (Spatial Land Analysis Manual') which is composed of (1) an operations manual, (2) flight 

manuals for each of the Spatial Land Analysis models; (3) an Operator Training Manual, and ( 4) 

a Maintenance and Inspection Manual. Please note that all the Spatial Land Analysis Manual 

(including all of the above listed components) are clearly marked "Confidential" on each page and 

contain confidential commercial and proprietary information that Spatial Land Analysis has not and 

will not share with others who are not subject to a "Nondisclosure Agreement" (NDA). Therefore, 

the Spatial Land Analysis Manual (including all components) are not available to the public and 

contain operating conditions, procedures and other information that are protected from public 

release or disclosure under the Freedom of Information Act 5 USC Sec. 552 et seq. 

1 Company Description 

This section responds to the specific requirements of 14 CFR Sec 11 .81. 

Provides advanced imaging and analysis using Small Unmanned Aircraft for precision agriculture. 

Mailing address and other contact information. 

ATT :Sean Wagner 

Spatial Land Analysis, LLC 

11824 Manning Park Ct 

Bakersfield, CA 93311 

Email: seanwags@gmail.com 

2 Relevant Statutory Authority 

This exemption application is expressly submitted to fulfill Congress' goal in passing Section 333(a) 

through (c) of the P.L. 112- 95, the FAA Modernization and Reform Act ('Reform Act'). This law 

directs the Secretary of Transportation to consider whether certain unmanned aircraft systems may 

operate safely in t he national airspace system ( AS) before completion of t he rulemaking required 

under Section 332 of the Reform Act. In making this determination, the Secretary is required to 

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determine which types of UASs do not create a hazard to users of the NAS or the public or pose a 

threat to national security in light of the following: 

• The UAS's size, weight, speed, and operational capability; 

• Operation of the UAS in close proximity to airports and populated areas; and 

• Operation of the UAS within visual line of sight of the operator. 1 

Lastly, if the Secretary determines that such vehicles "may operate safely in the national airspace 

system, the Secretary shall establish requirements for the safe operation of such aircraft in the 

national airspace system."2 

The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This statutory authority by its terms includes exempting civil aircraft, as the term is defined under §40101 

of the Act, that includes sUASs, from the requirement that all civil aircraft must have a current 

airworthiness certificate. 

3 Qualification for Approval Under Section 333 of the Reform Act 

The proposed operations in this petition for exemption qualify for expedited approval under Section 

333 of the Reform Act. Each of the statutory criteria and other potentially relevant factors are 

satisfied. The requested exemption would permit Spatial Land Analysis to perform commercial 

operations under controlled conditions in airspace that is 1) limited 2) predetermined 3) restricted, 

limited, or controlled as to access and 4) would provide safety enhancements to the already safe 

operations in these industries presently using conventional aircraft. Approval of this exemption 

would thereby enhance safety and fulfill the Secretary of Transportation's (the FAA Administrator's) 

responsibilities to "establish requirements for the safe operation of such aircraft systems in the 

national airspace system." Section 333(c) of the Reform Act. 

Each Spatial Land Analysis sUAS weighs 55 lb. or less including payload. Each Spatial Land 

Analysis sUAS operates under normal conditions at a speed of no more than 87 knots. Each 

Spatial Land Analysis sUAS has the capability to operate in either Automatic' or Ma.nuaP mode 

as described in the Spatial Land Analysis Manual. 

Generally Spatial Land Analysis sUAS operations will be below an altitude of 400 ft . AGL, within 

specific access-restricted areas, either within Class G airspace or with the permission of the ATC, 

using sUAS operated by Spatial Land Analysis-qualified sUAS pilots, and within the visual line 

of sight of the operator and observer. Such operations will insure that the sUAS will "not create 

a hazard to users of the National Airspace System or the public" as per the FMRA 2012 Section 

333. Given the size of the sUAS and the operating environment, this petition for exemption meets 

an equivalent level of safety, in which Congress envisioned that the FAA must, by exemption allow 

commercial operations of UASs to commence immediately. Also due to the size and environment, 

approval of the application presents no national security issue. 

1 Public Law 112- 95, 'FAA Modernization and Reform Act' Section 333 (a) 

2 Id. §333(c). 

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Considering the clear direction in Section 333 of the Reform Act, the authority contained in the 

Federal Aviation Act, as amended, the equivalent level of safety surrounding the proposed operations, and the significant public benefit described herein, t he grant of the requested exemptions is 

also in the public interest. 

4 Spatial Land Analysis Description of Proposed Operations 

Spatial Land Analysis operations will provide a level of safety that is equivalent to current aviation standards. Spatial Land Analysis safety procedures, risk assessments, and flight operations 

standards are described in detail in the accompanying Spatial Land Analysis ManuaL In brief, 

the following procedures that apply during operations conducted under this exemption request, 

establish an equivalent level of safety (ELOS) as follows: 

1. The sUAS will weigh less than 55 lb. 

2. Flights will be operated within line of sight of a pilot and/ or observer. 

3. Flights will occur during daylight hours. 

4. Flights will occur during Visual Flight Rules Meteorological Conditions (VMC). 

5. Flights will generally be operated at an altitude of no more than 400 feet AGL and withi n Class 

G airspace. Operations in controlled B,C, or D airspace will be conducted in coordination with 

t he proper FSDO and ATC with prior permission. 

6. Flights will be terminated at 25% or 5 minutes (whichever is greater) battery power reserve 

should that occur during the operation. 

7. All Spatial Land Analysis sUAS will be U.S. registered and display marks either in accordance 

with 14 C.F.R. Part 45, Subpart C or approved alternative markings. 

8. Operations will be conducted in defined regions and over property authorized for this use by 

the landowner. All operations will remain within the geographic boundaries of the operating area. When possible operations may be conducted within the limitations of the blanket 

COA authorization provided with 333 grants as of 3/ 23/ 2015. Otherwise the required FAA 

permission will be obtained. 

9. All required permissions and permits will be obtained from territorial, state, county or city 

jurisdictions, including local law enforcement, fire, or other appropriate governmental agencies. 

10. The operator will obtain the consent of all persons involved and ensure that only consenting 

persons will be allowed within 100 feet of the flight operation, and this radius may be reduced 

to 30 feet based upon an equivalent level of safety determination. 

11. A briefing will be conducted in regard to the planned sUAS operations prior to each day's 

activities. It will be mandatory that all personnel who will be performing duties within the 

boundaries of the safety perimeter be present for this briefing. 

12. lvlinimum crew for each operation will consist of the sUAS Pilot, t he Visual Observer. 

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13. Operations without a Visual Observer (sUAS Pilot only) may occasionally be conducted subject to additional and specific aircraft equipment, operator competency, and flight restrictions 

(maximum distance from the sUAS Pilot, maximum altitude, and maximum speed) as defined 

in the Spatial Land Analysis Operations Manual. 

14. sUAS operations under this exemption will be conducted under the supervision of a designated 

pilot in command (PIC) who has final responsibility for the operation and in accordance with 

14 C.F.R. 91.3. All sUAS operators must have completed training on the normal, abnormal, 

and emergency procedures in the Spatial Land Analysis Manual and demonstrated proficiency 

with the sUAS being operated. The PIC will meet at least the minimum FAA sUAS regulations 

for licensure. Currently, therefore, Spatial Land Analysis PICs must possess at least a sport 

pilot certificate and hold a valid U.S. driver's license. 

15. sUAS Pilot will be Pilot in Command (PIC). If a pilot certificate holder other than the sUAS 

Pilot, who possess the necessary PIC qualifications, is also present (i.e. the Visual Observer), 

that person can also be designated as the PIC. 

16. Observer and pilot will at all times be able to maintain verbal communication, either directly 

or through electronic means. 

17. Operators and engineers will maintain the sUAS system in a. condition for safe operation 

according to the Spatial Land Analysis Manual and associated manufacturer's maintenance 

manuals, including pre-flight and post-flight inspections. 

18. T he PIC and observers will maintain situational awareness and perceive, process, and perform 

risk management prior to and during each operation as described in the Spatial Land Analysis 

Manual. The PIC will terminate the operation in accordance with the Spatial Land Analysis 

:tvlanual if hazards that cannot be acceptably mitigated are observed. 

19. sUAS will safely stop operating and either return home or auto-land at a safe location along 

the flight path if the control link is lost. 

20. For each sUAS, the PIC will have the ability to force a controlled landing at any time. 

In addition to the above, Spatial Land Analysis has implemented a Safety Management System. The 

Spatial Land Analysis Safety :tvlanager is responsible for conducting safety audits, investigations, 

and inspections and is authorized to stop or prohibit any activity or operations which is considered 

unsafe. Full detajls are available in the Spatial Land Analysis Manual. 

5 Regulations From Which Exemption is Requested 

5.1 Part 61 , Certification: Pilots, Flight Instructors, and Ground Instructors 

Extent of Relief 

Part 61, all sections. 

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Reason for Relief 

Because the U AS will not carry a pilot or passengers, the proposed operations can achieve the 

equivalent level of safety of current operations by requiring the PIC operating the aircraft to have 

at least a sport pilot's license rather than a commercial pilot's license to operate these sUAS. 

Equivalent Level of Safety 

Unlike a conventional aircraft that carries the pilot and passengers, the sUAS is remotely controlled 

with no living thing on board. The area of operation is controlled and restricted, and all flights 

are planned and coordinated in advance as set forth in the General Operations Manual (GOM). 

The level of safety provided by the requirements included in the GOM exceeds that provided by 

a single individual holding a commercial pilot's certificate operating a conventional aircraft. The 

risks associated with the operation of the sUAS are so diminished from the level of risk associated 

with commercial operations contemplated by Part 61 when drafted, that allowing operations of 

the sUAS as requested with a sport pilot certificate as the PIC exceeds the present level of safety 

achieved by 14 C.F.R. §61.113 (a) & (b). 

5.2 61.113 Private pilot privileges and limitations: Pilot in command. 

Ext ent of Relie f 

Relief from requirement to possess a private or commercial pilot's license for aerial work such as 

aerial survey and mapping. 

Reason for Relief 

§61.113 (a) stipulates that a holder of a private pilot certificate may not act as a pilot in command 

of an aircraft for compensation or hire; (b) states that a private pilot may act as PIC if the flight 

is incidental to business and does not ca.rry passengers or property. Furthermore, I - 8900.227 "Unmanned Aircraft Systems (UAS) Operational Approval" paragraph 16(c)(2)(c) "Operations without 

a pilot certificate" states that a operations which conform to said paragraph may be performed by a 

PIC that does not possess a private pilots license but that has completed FAA private pilot ground 

instruction and passed the FAA Private Pilot written test. In addition, there is no means currently 

of obtaining a commercial rating for UAS. Thus, we require relief in order to perform aerial work. 

P ub lic Benefit 

As described above, the public benefit includes exponential economic growth, enhanced safety, and 

improved precision agriculture capabilit ies. 

Equivalent Level of Safety 

Our operations fullfill all the requirements in N- 8900.227 16( c) (2) (c) for operations without a private 

pilots license. 

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5.3 91.7 Civil aircraft airworthiness. 

Extent of Relief 

91.7, all provisions. 

Reason for R elief 

Should the exemption be granted allowing commercial operation of the sUAS without an ajrworthiness certificate, no standard will exist for airworthiness of the sUAS. 

Equivalent Level of Safety 

Given the size and weight of these aircraft and the requirements contained in the GOM, a.n equivalent 

level of safety will be achieved by insuring compliance with the sUAS user manuals prior to each 

flight. 

5.4 91.119, M inimum safe altitudes: G ene r a l. 

Extent of Relief 

Section 91.119 establishes safe altitudes for operation of civil aircraft. 91.119(c) limits aircraft flying 

over areas other than congested areas to an altitude of 500 feet above the surface, except over open 

water or sparsely populated areas, and the aircraft may not be operated closer than 500 feet to any 

person, vessel, vehicle, or structure. 

Reason for Relief 

To provide for these operations, the sUAS are normally operated at or below 400 feet AGL. In 

addition, due to the nature of the proposed operations, the PIC and the observer may at times be 

less than 500 feet away from structures during the operation. 

Equivalent Level of Safety 

The equivalent level of safety will be achieved given the size, weight, and speed of the UAS as 

well as the location where it is operated. No flight will be taken without the required permission 

of the property owner or local officials. Because of the advance notice to the property owner 

and participants in the aerial activity, all affected individuals will be aware of the planned flight 

operations. Compared to flight operations with aircraft or rotorcraft weighing far more than the 

maximum 55lbs. described above and the lack of flammable fuel, any risk associated with these 

operations is far less than those presently conducted with conventional aircraft operating at or 

below 500 AGL in other industries. In addition, the low-altitude operations of the sUAS will ensure 

sepaJ·ation between these s U AS operations and the operations of conventional aircraft that must 

comply with Section 91.119. 

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5.5 91.121 A lt imet er Settings 

Extent of Relief 

§91.121 

Reason for Relief 

As the sUAS may not have a barometric altimeter, but instead a GPS altitude read out, an exemption may be needed. 

Equivalent Level of Safety 

An equivalent level of safety will be achieved by the operator, pursuant to the GOM and the Safety 

Check list, confirming the altitude of the launch site shown on the GPS altitude indicator before 

flight. 

5.6 91.151 , Fuel r equirem e nts for flight in VFR conditions. 

Ext ent of Relief 

§91.151, all provisions. 

Reason for Relief 

The provision requires fuel sufficient for one half hour flight beyond the destination. These sUAS, 

including todays longest endurance platforms, are unable to meet this requirement because of limited 

max flight times. 

Equivalent Level of Safety 

An equivalent level of safety can be achieved by limiting flights for the sUAS according to the safety 

limitations described in the GOM. This restriction would be more than adequate to return the 

sUAS to its planned landing zone from anywhere in its limited operating area. 

5. 7 91.405, 91.407, 91.409, 91.4 17 Ins p ection and Maintenance P rograms 

Extent of Relief 

§§91.405, l\tlaintenance required; 91.407, Operation after maintenance, preventive maintenance, rebuilding, or alteration; 91.409, Inspections; and 91.417, Maintenance records. 

Reason for Relief 

The part 91 provisions are not applicable to a sUAS of the described weight class. Furthermore, 

FAA certified mechanics for sUAS do not at this present time exist, so full compliance is not possible. 

The sUAS flown are modular and as such entire components including engines and propellers are 

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minor replacements rather than major repairs. Finally, continuous minor alterations and payload 

reconfigurations of sUAS are designed and required for the operation of sUAS and do not negatively 

impact airworthiness. 

Equivalent Level of Safet y 

Inspection and maintenance manuals are used to maintain the sUAS in airworthy condition. Each 

sUAS is maintained according to the manufacturer standard or higher by technicians proficient in the 

building, repair, and maintenance of the sUAS. Inspection and Maintenance manuals utilized contain 

all aircraft-relevant items as described in (43 Appendix D (Scope and Detail of Items). Maintenance 

records are maintained in the Operations Database; either online on the Skyward Platform, and are 

therefore immediately auditable by regulators on demand, or as otherwise determined by Spatial 

Land Analysis. Finally, manuals will be submitted to the local FSDO Aviation Safety Inspector or 

other appropriate FAA division directly. 

6 Public Interest 

Spatial Land Analysis believes that the enhanced safety achieved using a sUAS with the specifications described in this petition and supporting documents and by carrying no passengers or 

crew, rather than a manned aircraft of significantly greater proportions ca.rrying crew in addition 

to flammable fuel, gives the FAA good cause to find that the UAS operations enabled by this 

exemption are in the public interest. 

The outputs of safe, reliable, and regulatory compliant operations of sUAS provide economic benefits 

historically unparalleled since the invention of flight, benefiting stakeholders at every level, both 

public and private. Lawful, safe aerial robotics operations will create new high-tech employment 

that will stimulate city and state governments; improve industries, create new small and large 

businesses; infuse new interest in STEM for children; and increase the safety of citizens through 

enhanced first-responder capabilities. 

7 P rivacy 

All flights will occur over private, limited, or restricted-access areas with the property owner's prior 

consent and knowledge. Operations will be conducted by trained crew and all other individuals will 

either be a part of the operation or consent to be present at the t ime of operations. 

8 Federal Register Summary 

Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the Federal 

Register, should it be determined that publication is needed: 

Applicant seeks an exemption from the following rules: 14 C.F.R. §21, subpart H; 14 C.F.R 

45.23(b);14 C.F.R. §§61.113( a) & (b), 61.133(a); 91.7 (a); 91.9 (b) (2); 91.109; 91.119; 91.121; 

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91.151(a);91.203(a) and (b); 91.405 (a); 91.407 (a) (1); 91.409 (a) (2); 91.409 (a) (2) and 91.417 (a) 

& (b) to operate s U AS for commercial use. 

9 Conclusion 

Spatial Land Analysis seeks this exemption to conduct commercial operations using sUAS within 

restricted-access areas in the NAS. Without this exemption, sUAS innovation will be suppressed, 

the public economic benefits derived from increased sUAS development will be denied, and the 

Congressional directive to accelerate the integration of UAS into the NAS will be impeded. The 

sUAS physical and operational characteristics are compliant with those described in the FMRA and 

FAA's guidance for Sec 333 exemptions. Spatial Land Analysis respectfully requests that the FAA 

grant its petition for exemption from airworthiness. 

Please do not hesitate to contact Andrew McCollough, the Regulatory Services POC, via email at 

exemption@skyward.io if you have any questions or concerns. 

Very Respectfully Yours, 

SQ.Q\n ~,rmr Sean Wagner 

Spatial Land Analysis CEO 

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